FDIC Federal Register Citations

From: Chuck Armour
Sent: Monday, November 10, 2008 11:44 AM
To: Comments
Subject: Assessments - RIN-3064-AD35

At a time when many banks are struggling with the conflicting challenges of working through problem loans and, at the same time, maintain capital and modest levels of profitability, the proposed 7 basis point increase in the FDIC assessment rate seems ill timed.  While it is recognized an increase in necessary, it would seem that a graduated increase would better serve the needs of the FDIC, individual banks and the economy as a whole.

Beginning with a more modest increase, perhaps in the range of 3.5 basis points for the first year or two, would still serve the dual needs of increasing the insurance fund, while making it easier for many banks to absorb the additional expense.

Given the uncertain economic times we face, it would seem that pursuing any reasonable measure possible, in order to maintain the profitability of and confidence in our banking industry, would be well worth the effort.

Chuck Armour
SVP & CFO
Alden State Bank